Audit 399626

2025-003 Title I Eligibility CFDA Title: Title I Grants to Local Educational Agencies CFDA Number: 84.010A Federal Award Number: S010A240026 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: There is a lack of internal controls over documentation of Title I Eligibility for targeted Title I students. Context: A sample of 18 students receiving targeted Title I services was tested for eligibility testing. The District could not provide supporting records for eight selections of the sample, preventing verification of eligibility for those students and indicating systemic record retention issues. Criteria: The Elementary and Secondary Education Act and 2 CFR Part 200 require districts to maintain sufficient documentation to support student eligibility and retain records for audit, therefore, there should be policies and procedures in place as part of internal controls that addresses the maintenance and retention of documentation surrounding student eligibility in Title I. Effect: The school district was unable to provide original documentation for 8 of 18 students selected for review under targeted Title I eligibility. Inability to verify eligibility shows a weakness in internal controls and increases the risk of noncompliance and may result in questioned costs or repayment of Title I funds. Cause: There was a lack of internal controls as there were inadequate record retention practices and documentation management. Recommendation: It is recommended the district retain all required documentation to support Title I eligibility and strengthen internal controls to ensure records are complete, maintained, and accessible for audit.